Responding to a UDRP Complaint
By Casey Scott McKay ·
You have been named as the respondent in a UDRP proceeding and you have twenty days to save a domain name you believe is legitimately yours. This guide is the respondent-side manual: how to read the notification and calendar the three dates that matter, how to triage the case in forty-eight hours, what evidence to lock down before you touch anything, and how to attack the three elements of Policy Paragraph 4(a) in the order they actually break rather than the order the complainant pleaded them. It works through the Paragraph 4(c) safe harbors in operational detail — bona fide offering, commonly known by the name, and legitimate noncommercial or fair use — along with the reseller test from Oki Data, the criticism-site split, and the dictionary-word and domain-investor defenses. It covers the three-member panel election under Rule 5(d) and when the two thousand dollars is worth spending, model response language you can adapt, the Rule 15(e) request for a finding of reverse domain name hijacking, and what a late or defaulted response is really worth. It closes with the ten-business-day window under Policy Paragraph 4(k), the federal suit under 15 U.S.C. 1114(2)(D)(v) that freezes the transfer, and the counterclaim exposure that makes most respondents decide not to file it.
IP and Technology > Internet | Guide | Published 15 January 2026 - Updated 21 May 2026 | Casey Scott McKay - marksy.us
Summary. You have been named as the respondent in a UDRP proceeding and you have twenty days to save a domain name you believe is legitimately yours. This guide is the respondent-side manual: how to read the notification and calendar the three dates that matter, how to triage the case in forty-eight hours, what evidence to lock down before you touch anything, and how to attack the three elements of Policy Paragraph 4(a) in the order they actually break rather than the order the complainant pleaded them. It works through the Paragraph 4(c) safe harbors in operational detail — bona fide offering, commonly known by the name, and legitimate noncommercial or fair use — along with the reseller test from Oki Data, the criticism-site split, and the dictionary-word and domain-investor defenses. It covers the three-member panel election under Rule 5(d) and when the two thousand dollars is worth spending, model response language you can adapt, the Rule 15(e) request for a finding of reverse domain name hijacking, and what a late or defaulted response is really worth. It closes with the ten-business-day window under Policy Paragraph 4(k), the federal suit under 15 U.S.C. § 1114(2)(D)(v) that freezes the transfer, and the counterclaim exposure that makes most respondents decide not to file it.
Keywords: udrp response · domain name respondent · rule 5 deadline · rights or legitimate interests · registered and used in bad faith · reverse domain name hijacking · oki data reseller test · three-member panel election · wipo jurisprudential overview · mutual jurisdiction · acpa section 1114(2)(d)(v) · domain name lock · gripe site defense · dictionary word domain · domain investor · late response and default · uniform rapid suspension · cybersquatting defense
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